SEC’s Supervision Initiative Risk Alert

On July 23, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert, which discussed its observations from examining firms that currently employ or previously employed supervised persons with a history of disciplinary...

Fiduciary Duty Goes Well Beyond Share Class Selection

Investment advisers may have noticed the SEC’s recent Share Class Selection Disclosure Initiative and thought they had nothing to learn from the 79 enforcement actions. The reality is that even investment advisers who are not affiliated with a broker-dealer can...

SEC Announces Its 2019 Examination Priorities

The SEC’s Office of Compliance Inspections and Examinations (OCIE) publishes annually its examination priorities to promote transparency and provide insights into the areas it believes pose a heightened risk to investors or to the integrity of the U.S. capital...

Supervision of Investment Adviser Representatives

Registered Investment Advisers (RIAs) owe a duty to supervise persons associated with the firm with respect to activities performed on their behalf. In recent deficiencies letters, RIAs have been criticized for failing to adequately supervise their supervised persons,...